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The Center for Medicaid and Medicare Service’s Final Settings Rule mandated that all home and community-based services shift to a person-centered delivery method by March 17, 2023, giving providers five years to make the necessary changes.
At the time the Rule was made, services included in HCBS recipient care plans were generally selected by providers, with limited input from recipients about their goals and preferences. In contrast, a person-centered approach to HCBS incorporates the goals, values and preferences of recipients to help support them in leading the lives they want to lead.
While many states and organizations have been using a person-centered approach to HCBS, the new Rule means that many providers will need to undergo major changes in relation to the way their services are designed and delivered.
But how will organizations and providers of HCBS know if their services are truly person-centered? And how will they know if those services are high-quality?
That’s where CMS’s proposed Access Rule comes in. The rule includes a set of measurement tools (called the HCBS Quality Measure Set) they suggest should be used to evaluate person-centered services. But there are widespread concerns about the measures shared by many in the HCBS community.
Some of the concerns about the HCBS Quality Measure Set include the validity of the tools (do they really measure what they are designed to measure?), the lack of clarification about selecting and using the tools and the lack of transparency on how CMS plans to use data generated by using the tools.
“If these concerns are not addressed, it could lead to data that does not properly reflect the person-centered outcomes for HCBS recipients, causing resources to be directed in ways that don’t truly support improved outcomes” states Bridgette Schram, PhD, CROR program manager for the RRTC HCBS grant.
To help address these concerns, both of NIDILRR’s RRTCs on HCBS (at Shirley Ryan AbilityLab and the University of Minnesota) developed a set of recommendations and talking points that HCBS service providers could use to respond to the proposed rule during the public comment period which ended July 3.
The RRTC’s recommendation to CMS include:
- Measures included in the HCBS Quality Measure Set should be valid, reliable, feasible to use and should be reviewed and change over time if needed.
- Data collected through the measures should be publicly available, and a plan for how the data will be used should be transparent.
- CMS should provide resources to improve the feasibility of long-term implementation and use of the measures.
Although the comment period has closed, this is a discussion that is just beginning, says Schram. “It is important we advocate for the use of validated measures and support in using them now rather than after these measures become a part of established systems.” she explains.
For the RRTC’s full recommendation document, please click Download below.